Requirements for coronavirus disease 2019 (COVID-19) apps

This article was last updated on January 6, 2022. The following sections were updated:

  1. Step 1 of the "App requirements" section:
    • Clarified that all contact tracing and COVID-19 status apps, including ones that merely store an individual’s vaccination or test records, need to complete the "COVID-19 contact tracing and status apps" section in the App content page.
    • Additional requirements are introduced for apps that plan to remove contact tracing or COVID-19 status functionalities.
  2. Step 2 of the "App requirements" section:
    • Clarified proof of permission requirements for different app types.

Due to the unprecedented worldwide emergency, Play is expediting reviews to enable official apps intended to respond to the COVID-19 pandemic to publish on the Google Play store. Google takes this responsibility very seriously, and in the interest of public safety, information integrity and privacy, only specific COVID-19 apps that meet the requirements below will be allowed on the Google Play store.

What apps are subject to COVID-19 restrictions?

Apps that are subject to these requirements include, but may not be limited to:

  1. Apps that provide medical, treatment, vaccine, testing, or other related information for COVID-19.
  2. Apps that support COVID-19-related response, containment, research, or education/training efforts.
  3. Apps that support services used to respond specifically to COVID-19, for example, apps that provide social support (food stamps, payment), healthcare, loans, and so on, specifically in response to COVID-19.

Note: Only apps in these categories may use, approximate or leverage coronavirus, COVID-19, pandemic, or related keywords in their Google Play store title and/or icon.

Other apps may use COVID-19 related terms in their in-app experience, their app description, or app screenshots but not in their title and/or icon. For non-medical related apps, references to COVID-19 are limited to non-health related claims (for example, opening hours changes, sharing tips on activities to do at home, providing commentary on the economic/social impacts of COVID-19, and so on). These apps may not include health claims (for example, prevention methods, treatments, vaccines).

Eligible COVID-19 apps

Apps in categories 1-3 above must be one of the following:

1. Official Governmental apps: Eligible for COVID-19 resource portions of the Google Play store

In the interest of connecting users to authoritative information and services, only COVID-19 apps published or commissioned by an official government entity are permitted to be featured in COVID-19 resource portions of the Google Play store. Only apps in this category are eligible to publish publicly available contact tracing apps (see below).

2. Verified health apps: Eligible for usage of COVID-19 related titles, icons, and marketing in Google Play store listings

In the interest of protecting user safety, only official Governmental apps and the following categories of apps are eligible to use COVID-19 or other related keywords and marketing in their Google Play store app title and app icon:

  1. Official governmental apps as defined in section (1) above, or
  2. Apps published by or in direct affiliation with:
    • a healthcare system or provider (for example, CVS Health, UK National Health Service, UnitedHealth Group, Kaiser Permanente, French national healthcare system, Netcare (South Africa), One Medical, and so on); 
    • a nationally recognized medical or epidemiological research organization deeply rooted in medical research (including nationally recognized medical schools). (The medical or epidemiological research organization or government research, should have approval from a registered governing body (for example, Institutional Review Board in the US, or the National Health Service (NHS) in the UK). In case of dispute, a local or national government, or verifiable healthcare non-governmental organization (NGO) endorsement will be required.

* Please note for apps to meet the criteria in sub-section (b) above, the app must be directly published by or in direct partnership with the one of the entities (for example, the authorizing institution or organization is referenced, with full permission, in the app’s title, logo, or Google Play store description). Endorsement by a non-government entity alone does not meet the qualification. (for example, an app endorsed by staff at a medical school would not qualify if that app is not published by or in direct partnership with the medical school).

App requirements

1. Complete the "COVID-19 contact tracing and status apps" section in the App content page

If your app is a COVID-19 contact tracing and/or status app, please go to the App content page (Policy > App content) in Play Console, and provide the required information in the "COVID-19 contact tracing and status apps" section.

To determine if your app is a COVID-19 contact tracing and status app, please use the guidance below:

  1. Publicly available COVID-19 contact tracing apps include all apps that track or monitor infected or exposed individuals for the purpose of COVID-19 responses or mitigation.
  2. Publicly available COVID-19 status apps include apps that verify an individual’s vaccination status, current infection, or history of infection, for example, for the purposes of determining the individual’s eligibility for travel or entry into public spaces. Note that this also includes apps that merely store an individual’s vaccination or test records but do not interpret this data and issue public health conclusions.

Note: If you plan to significantly change your app functionality, such as adding or removing contact tracing or status-storing functionalities, you will need to update your declaration in the “COVID-19 contact tracing and status apps” section of the App content page in your Play Console account.

You will also need to alert your users (for example, update the "What’s new" section) and update the store listing. If you plan to rescind contact tracing or status-storing functionalities and unpublish the app, you will also need to update the declaration and store listing, and alert your users via an in-app notification. You may refer to the Enabling Dishonest Behavior policy for additional guidance.

2. Submit proof of eligibility via the Advance Notice Form

To speed up the review process, before submitting your eligible app in Play Console, please use the  Advance Notice Form to submit proof that your app meets the criteria of sections 1 or 2 of Eligible COVID-19 apps above.

If you’ve declared your app as a publicly available COVID-19 contact tracing app or status app in step 1., your app must be published, commissioned, or directly endorsed by an official government entity. The jurisdiction (applicable geographical region) for that endorsement must be declared when submitting proof of eligibility via the Advance Notice Form, and must be prominently disclosed in the app's Play store listing. An example of sufficient proof includes a detailed communication on the official letterhead of the relevant government entity or organization, that includes the specific title and package name of the app.

Note: apps that merely store an individual’s vaccination or test records but do not interpret this data and issue public health conclusions may also be published by, or in affiliation with, any of the entities in Section 2(2) of Eligible COVID-19 apps above. Where applicable, healthcare organizations should also provide their national registration number such as NPI (US), NIN (in India), and so on.

3. Privacy requirements

All COVID-19 apps must strictly comply with all Google Play Policies, including but not limited to the following requirements:

  • If your app accesses, collects, uses, or shares personal or sensitive user data, including any functionality or data regulated by dangerous or runtime permissions (including location, address book, BSSID, BLE, photos, microphone, health sensors), the app must meet our prominent disclosure and consent requirements, prior to beginning collection or handling of the personal or sensitive user data. This disclosure should include COVID-19-related uses as well as uses required to comply with valid legal processes.
    • If subsequent versions of your app collect new types of personal or sensitive user data, you must re-prompt users with a notification and rationale behind the new data being collected.
  • Apps must have a publicly accessible privacy policy that comprehensively discloses the access, collection, use and sharing of personal and sensitive user data. 
  • Apps created specifically for the COVID-19 response may not access personal and sensitive data that is not required to directly support the public health emergency, and may only use the data collected to support COVID-19-related efforts or epidemiological research or to comply with valid legal processes. The app’s privacy policy must reflect this limited use. If data may be used or shared to comply with valid legal process, this must be clearly disclosed in the privacy policy, along with a link to available information about the relevant law and any user rights to contest legal data requests.
  • Apps that serve a user need in addition to a COVID-19 response (for example, multi-purpose governmental apps or “telehealth” apps) may only use the data acquired for COVID-19 related purposes in conjunction with the app’s user-facing purpose(s). 
    • For example, it should be clear to the user the connection between the app’s core functionality and the collection of COVID-19 related data. 
    • If this requirement is currently unmet, you must modify the existing app to meet the above requirement so collection and use of COVID-19 related data is clearly part of the core purpose of the app, and you must clearly communicate this change to existing app users before the data is collected, for example, by including a prominent in-app disclosure prior to collecting the new COVID-19 related data. Alternatively, you can release a dedicated COVID-19 related app.
    • You must disclose the use of COVID-19 related data in user-facing privacy disclosures (for example, privacy policy and/or in-app disclosures) for your app(s).
  • Apps must handle all personal or sensitive user data securely, including transmitting it using modern cryptography (for example, over HTTPS).

4. App visibility and user awareness

COVID-19 apps that collect, poll, listen for, or handle personal and sensitive user data must strictly comply with all Google Play Policy requirements, including: 

  • Contact tracing apps and COVID-19 status apps (see definitions above) must clearly disclose this functionality in their Play store listing. Apps that add contact tracing or proof of immunity functionality to a preexisting app must meet the app requirements as listed above, including proof of eligibility, privacy features, and prominent disclosure of new functionality to existing users.
  • Apps should not be headless. Apps must display a clearly identifiable icon in the app tray, device app settings, notification icons, and so on.
  • Apps must display a persistent device notification to the user using one of the following two methods depending on if the app runs in the background or foreground:
    1. For apps that collect information in the foreground or use foreground service: 
      • App must display a user-facing persistent device notification when the app is running and capable of automatically collecting this information (for example, app is listening for BLE handshakes, app is collecting location, and so on).
    2. For apps that collect information when running as a background service:
      • App must display a daily user-dismissible notification informing the user of the collection/polling/handling of this information. 
      • You may allow users to instead opt into weekly notifications (via in-app checkbox or settings), however, the default setting must be a daily notification. 

5. API requirements

In accordance with Google Play’s Device and Network Abuse policy, your app may not access or use any API in violation of their terms.

6. Editorial and quality requirements

In accordance with Google Play policies pertaining to Sensitive Events, Misrepresentation, and Deceptive Behavior, all apps offering COVID-19 related content must not contain or perpetuate: conspiracy theories, misleading claims, "miracle cures" or dangerous treatments, or any patently false or unverifiable information pertaining to COVID-19 (including authorities coordinating COVID-19 response), regardless of app categorization.

App review and visibility

Due to the extremely urgent and sensitive nature of distributing apps related to COVID-19 response efforts, there may be an increased level of enforcement, pursuant to the terms of the Developer Distribution Agreement, as well as the Enforcement Policy, in an effort to ensure the safety of users and the Google Play ecosystem. Developers are responsible for conducting extra due diligence to ensure that their apps are fully policy compliant at all times.

We will make every effort to ensure that apps being used in the COVID-19 response efforts remain on the Google Play store, barring a privacy, disinformation, or user harm risk that outweighs the public benefit. In cases where an app is found to have a less serious policy violation and presents a compelling public health benefit, it may be allowed to continue distribution on the Google Play store while the violations are being remedied. During this period, these apps may not be eligible for promotion on Google Play, including inclusion in dedicated COVID-19 resource portions of the Google Play store.

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